Royal Caribbean Cruise Ltd. v. Eduardo Whitefield, through Murillo Martines (personal representative)
This case is a declaratory judgment action involving the right of a cruise ship employee to receive maintenance and cure benefits.
Decedent Eduardo Whitefield ("Whitefield") was employed by plaintiff, Royal Caribbean Cruises, Ltd. ("Royal Caribbean"). Following Whitefield's employment he received maintenance and cure benefits for a number of health issues. Royal Caribbean determined that he reached maximum medical improvement and discontinued Whitefield's maintenance and cure payments.
Royal Caribbean filed this action seeking a declaration that it was no longer obligated to continue Whitefield's maintenance and cure benefits after they were terminated. Whitefield countered by filing an action seeking relief under the Jones Act and general maritime law for failure to provide maintenance and cure benefits.
Whitefield's Jones Act claim alleged negligent failure to provide adequate medical care (Whitefield died following the ending of the payments).
Whitefield moved to dismiss Royal's action because Whitefield had a pending Jones Act claim in state court.
Did this Court grant Whitefield's motion to dismiss?
Whitefield claimed that this action should be dismissed because there was a similar action pending in state court allowing this Court to properly exercise its discretion to dismiss the case. This Court recognized Supreme Court precedent that allows the dismissal of a federal action, that is being held in state court, to avoid interference with the state court litigation.
As such, Whitefield claimed this action should be dismissed in favor of the pending litigation in state court. This Court found that courts have taken a modified approach when the federal declaratory action involves a maintenance and cure claim and a pending state court action includes a Jones Act claim where both cases grew out of a single transaction or accident.
One factor, according to this court is the practicality of conducting a trial on the maintenance and cure claim under the district court's admiralty jurisdiction (without a jury) while the Jones Act claim would be tried in state court with a jury.
Another factor is the role of the Saving to Suitors Clause which establishes a plaintiff's right to jury trials and common law remedies in the forum of the claimant's choice.
Moreover, the Court will examine whether the parties are acting in bad faith to determine the dismissal of the federal declaratory judgment.
This Court found, under these circumstances, that it was likely some findings in this federal case would be res judicata to the state case if this case goes to trial first. The crux of this claim is whether Whitefield had reached maximum medical improvement while the Jones Act claim would have to determine whether Royal negligently cut off Whitefield's right to maintenance and cure.
Accordingly, this Court found that dismissal of this action, a declaratory judgment action for maintenance and cure, when a Jones Act claim is pending in state court.
This Court dismissed Royal's federal declaratory action, whether Whitefield had reached maximum medical improvement, because it found that the determinations in federal court, without a jury, would undermine the jury in the state Jones Act claim to conduct their fact finding.
To avoid such injustice, courts are given the discretion to dismiss claims so not to interfere with state court actions.
Steve Gordon
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